Santar S. Yei and Grace H. Yei - Page 4

                                         -4-                                           
          received $99,990 therefor.1                                                  
               In 1984, Mr. Yei acquired a controlling interest in Cirtex, a           
          circuit board manufacturer located in Santa Clara, California, and           
          became its president.  Mrs. Yei maintained the company's books and           
          records.  Cirtex had approximately 80 employees in the mid-1980's,           
          but that number fell to less than 10 by 1989 because of financial            
          difficulties.  The company's problems, including environmental               
          contamination at the company's manufacturing plant, brought about            
          several lawsuits. Cirtex was dissolved on May 22, 1992.                      
               We note that for all of the issues, petitioners have the                
          burden of proving error in respondent's determinations.  Rule                
          142(a); Welch v. Helvering, 290 U.S. 111 (1933).  Moreover,                  
          deductions are a matter of legislative grace, and petitioners bear           
          the burden of proving they  are entitled to any deductions claimed.          
          See INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992).                   
          Issue 1.  Stock Sale                                                         
               Pursuant to a written agreement dated December 9, 1989, Mr.             
          Yei surrendered (for cancellation) 60,000 shares of Cirtex stock to          
          Cirtex.  He received no money in connection with this transaction.           
          According to the December 9, 1989, agreement, Mr. Yei surrendered            

               1    Although the record is far from clear with respect to              
          this matter, it appears that from the time Mr. Yei acquired the              
          10,000 shares of Solectron stock in 1979 to the date he tendered             
          his stock to Solectron, there had been a 3 for 1 stock split or              
          dividend and a subsequent 2 for 3 reverse (downward) stock split.            
          Hence, we believe that in 1989, Mr. Yei owned 19,998 shares of               
          Solectron stock all of which he tendered to the Company at $5 a              
          share (the tender price).                                                    




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